The URL can be used to link to this page

Home My WebLink About01-2450 FX LAW OFfiCES SNELBAKER. BRENNEMAN & SpARE "c..,..,._..._ -', "~oj ''',.-,,-~,'--, ~'-- -'. MICHAEL ], MALPEZZI, trading and doing business as MALPEZZI FUNERAL HOME, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2001- e:l'l?O e;;j Plaintiff v, CAROLANN WENDLAND, CIVIL ACTION - LAW Defendant NOTICE You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with a court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, p, C. By: ,l1tw~ Attorneys for Plaintiff LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ,.- _.- - __.. :',. _ "~: _ ',:"'0;" . _ - . '. - . MICHAEL 1. MALPEZZI, trading and doing business as MALPEZZI FUNERAL HOME, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2001- ;(<lSb Ct;.:J ,.~ Plaintiff v, CAROLANN WENDLAND, CIVIL ACTION - LAW Defendant COMPLAINT Michael 1. Malpezzi, trading as Malpezzi Funeral Home, by his attorneys Snelbaker, Brenneman & Spare, P. C, files this Complaint and in support thereof states the following: 1. Plaintiff Michael 1. Malpezzi is an adult individual trading and doing business as Malpezzi Funeral Home with a business address of 8 Market Plaza Way, Mechanicsburg, Cumberland County, Pennsylvania, 2, Defendant Carolann Wendland is an adult individual residing at 1464 Boiling Springs Road, Boiling Springs, Cumberland County, Pennsylvania. 3, On or about May 26, 2000, Defendant entered into an agreement with Plaintiff whereby Defendant agreed to pay for various goods and services selected as well as certain costs advanced by Plaintiff with respect to the funeral of Carol M. Wendland, A true and correct copy of the agreement dated May 26, 2000 entitled "Statement of Funeral Goods and Services Selected" as executed by Defendant (hereinafter the "Agreement") is attached hereto and incorporated by reference herein as "Exhibit A". LAW OFFICES SNELBAKER, BRENNEMAN & SPARE '-',,',,"C. ~-"l', 4, In accordance with the terms of the parties' Agreement, Defendant was to pay Plaintiff the sum of $3,637.00 within thirty (30) days of May 26, 2000 for the goods and services provided and costs advanced by Plaintiff pursuant to the Agreement. 5. Plaintiff provided the goods and services selected and agreed to by Defendant pursuant to the Agreement without objection or complaint by Defendant. 6, Defendant has failed and refused to pay Defendant the sum of$3,637,OO pursuant to the terms of the Agreement. 7, Defendant's failure to pay to Plaintiff the sum of$3,637.00 within thirty (30) days of May 26, 2000 constitutes a material breach of the parties' Agreement. 8, Pursuant to the terms of the parties' Agreement, Defendant acknowledged that a late fee of one percentum (l %) per month would be applied to the unpaid balance due Plaintiff beginning thirty-one (31) days from May 26, 2000. 9, Pursuant to the terms of the parties' Agreement, Defendant agreed to pay all reasonable costs and expenses incurred by Plaintiffto collect amounts owed by Defendant under the Agreement, including attorney's fees, court costs and other costs. 10, All conditions precedent to Plaintiffs right to maintain this action have occurred. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $3,637.00, together with late charges of $36.37 per month beginning June 26, 2000 until the sum of $3,637,00 is paid in full, as well as reasonable attorney's fees and costs of this action, -2- CO';" LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ^.' .-., '~",L 'C ,,'L, _~,_;. ;, >. ,,__ ,_-;",::~_', ,_o,'_",,","'j,'-'_;'_,,' ~., '" "'~~:_", The amount claimed in this action, exclusive of interest and costs, does not exceed the amount established for mandatory arbitration in Cumberland County. SNELBAKER, BRENNEMAN & SPARE, P. C. Iflhtf1141- BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg,PA 17055 (717) 697-8528 Attorneys for Plaintiff Michael 1. Malpezzi, trading and doing business as Malpezzi Funeral Home Date: Apri125,2001 -3- r~~" StATEMENT OF FUNERAL GOODS AND SllRVICES SELECfED IJl Charges are only for those items that you selected or that are required. If we are required by law or by a cemetery or crematOlY to use any items we will explain the reason in writing below. ' ~fyou sel~cted a funeral that may require embalming, such as a funeral with viewing, you may have to pay for embalming. You do nol have to pay for embalm. mg you did not approve if you ~ected arrangements such as diJect,cremalion or immediate burial. If we charged for embalming, we will explain why below. FOr the SuvJce 01 A L _ c..t../ b'/f...-"..d L,AI "h..-..f) Date of Death ~:A . oJ Charge to: (!.A'/l_J~/P/f..;,/t..;' t:U;,f'7V,/JL~ ,v. r I Name Address City Slate A. CHARGE FOR SERVICES SELECTED: Other clothing 1. PROFESSIONAL SERVICES Services of Funeral Director/Staff . . .. 5----L... Embalming...................... ,=::z- Other preparation of body -~.~'~~~ I---,_".~~.= . ",__ ..................... ....i_ SVB. TOTAL OF PROFESSIONAL SERVICES. . 2. FACILITIES AND SERVICES Use of facilities and services for viewing (VisitationIWake)......... $_ Use of facilities and services for funeral ceremony ....... .... $_ Use of facilities and services for MemorialService........ ...._ Use -of equipment and services forgravesideservice. .$ ~ Other use of facilities AI'_ ......................i_ SUB-TOTAL OF FACILITIES/EQUIPMENT. 3. AUTOMOTIVE EQUIPMENT Vehicle to transfer remains to Funeral Home~ Local...........................$_ Hearse (Caliket Coach) Local..... . Limousine Local. . Family car Local............................_ Flower car or floral disposition Local.............. Lead car/clergy car local."..... Car for pallbearers Local..... . Out of town transportation. . . . ....A2._ / ....i_ ....i_ i_ i(/ ....i_ .....i_ i- i- SUB.TOTAL OF AUTOMOTIVE EQUIPMENT. . . . . . .. A3 $_ TOTAL OF PROFESSIONAL SERVICES, FACILITIES AND AUTOMOTIVE EQUIPMENT ................................... A ,. ',L., "-~J:&:ll~U> - Cremation urn (Description) I- I- ...'- OTHER I- i- i_ . . . B ...A2.t9 - TOTAL MERCHANDISE SELECTED. C. SPECIAL CHARGES: Forwarding of remains to '- (Funeral Home) Receiving of remains from (Funeral Home) Immediate BuriaJ. Direct Cremation. . . . . ...~ .'- '- SUB-TOTAL OF SPECIAL CHARGES D. CASH ADVANCED Opening Grave.... ... '(1/ t' Cemetery Equipment. ...'_ Lot and Deed.... ....._ Newspaper Notices-Local .. . . ==--- Newspaper Notices-Out-of-town. . .. $_ Telephone & Telegrams ...... '_ Airfare.... ........_ Clergy/Malis Offering. .. $~- Pallbearers.............. ....S_ Certified Copies of the Death Certificate.. ........... Police Escort Flowef5 ... Vault Service Charge. . . ....C$_ i~ .....i_ ...1- .....i_ i- i- I- I- i- i- , o i-.LLk SUB-TOTAL OF ADVANCES........ We charge you for our services in obtaining: (SPecify cash advances thatJjle marked-up) A.h:!J/Va i.z.tJr - 8. CHARGE FOR MERCHANDISE SELECTED: ~~~::i~~i~~)'-za' i;'~': J4~-~~ $.&..:i:q- <',4> seiP'V. Other Receptacle ................. $_ (Description) Outer burial container .............._ (Description) Acknowledgement cards ........... ._ Registerbook(s) ..................._ Memory folders ..................._ Prayercards.....................$_ Temporarygravemarker........... ._ Burial clothing ........ ... $_ SUMMARY OF CHARGES A. Professional Services, Facilities and Equipment, and Automotive Equipment............. I~- B. Merchandise..................... .L.s.ti:I) - C. Special Charges .................. $_ D. Cash Advances................... $~- .J/.. '2 -j- TOTAL OF ALL SECTIONS. . . . . . . . . . . . . $)l-I!-L-l PAID AT TIME OF OR PRIOR TO () ARRANGEMENTS................ ......._ BALANCEDUE........... ...... '.J--ia-S:l-- REASON F.PR. I ~ING /._ ~N./?~'~ If any law, cemetery, or crematory requirements have required the purchase of any of the items listed above the law or requirement is explained below. --- I agree that I have examined the items of goods and services selected above and found them to be correct a~d according to the arrangements I have requested. I acknowledge receipt of a copy of this Statement of Funeral Goods and Services Selected. I represent that I have suffioent funds available for paymelll of the cash price for the goods and services selected. I also agree to ~aymeDt of .1 " 1 7 - within "J 'j) days. I agree to be joindy and severally liable with anyone else who Signs below. A late cbarge of / per month amounting to ,].:.T}:.... per year wl1l be applied to the unpaid balance beginning J ( d2ys from the date of this agreement.IWin also pay to the Funeral Director aU'reasonable costs paid by the Funeral Director to collect amounts I owe under this agreement. 'those costs may Include attorneys' fees, court costs and other costs. Any additional services or merchandise ordered or requested after the date of this agreement will be considered pan of this agreement and the cost thereof will be reflected on tbe final bill or statement. (Seal) (Seal) ~ CMt..tO,...lJ:":~ 0 Q 1\ J ~ (Purchaser ~PcnlUylvanlaFuna:llDlr<<torsAsMlclJdon form - 600 Revised 4/94 /IIA''1' Z 6 :/-OOD (Date) , /M'L~~ ,-> (Uc d uneral t6'fJV WHITE FuneL';lL Ol"'t1or YELLOW FUlIenl Dl' EXHIBIT A ' PINK Customer . ~ '-" -, , LAW OFFICES SNELBAKER. BRENNEMAN & SPARE VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4909 relating to unsworn falsification to authorities. Michael 1. Maln ZI, 3mg and doing business as Malpezzi Funeral Home Dme: April 25, 2001 ~8~~~~":Iir~iil<~~tii;j~_~l);fli's'i'l#,,"-ii,~!"Jol',,,*.!f;m~I1.~~~......-ii&:iii"~" - -" I!:thlh. "'~ UliJ~ H ~ ~ n P;;1!, l F' 0 0 O~ C -'1 . lJ\ 5: roo ,-, ""OrT' -0 f1i p1 ~ ~ rnm =0 ;;;;;::0 N '-qrn ZC X (f) Z: 0' ...\J ~ -<....:- 20 kO .." ~:;:::~ ~ ~Q :x ?t-) ---0 ~ om ........ )>c ~ ~ Z r;., ~ -l -:: -:: '-J ~ :";~';',r-;'" ,.{4),,-,~,JfJ;;,[ ro-. ," \)1, ,~>~~umWJ ",""t<'..,"~, _,~ ""T'" ","" ",~'_'" -1__','__, _ <. tJj ~"~.,,~,~..I.>. ,_ . ~" """""""',-~. ,_ ~t 1.10 -iAllt;il!ii@",,*~_,. SHERIFF'S RETURN - REGULAR CASE NO: 2001-02450 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MALPEZZI MICHAEL VS WENDLAND CAROLANN CPL, MICK BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WENDLAND CAROLANN the DEFENDANT , at 1951:00 HOURS, on the 3rd day of May , 2001 at 1464 BOILING SPRINGS ROAD BOILING SPRINGS, PA 17007 by handing to CAROLANN WENDLAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.72 .00 10.00 .00 31.72 So Answers: r~~-C~ R. Thomas Kline Sworn and Subscribed to before 05/04/2001 SNEL~R~~~ Deputy Sheriff ' me this J.3~ day of 7; ;;"'1 AD <. ;;> "ht,/i,.-', -- . . ~othonotary ~ ; , . t ' MICHAEL J. MALPEZZI, trading and doing business as MALPEZZI FUNERAL HOME, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff : NO. 2001-2450 Civil v. CAROLANN WENDLAND, : CIVIL ACTION - LAW Defendant TO: Carolann Wendland Date of Notice: May 24, 2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: '.'j :~ ::,! , !~j I~>I Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, p, C. t4 LAW OFFICES SNELBAKER. BRENNEMAN & SPARE By: Keith O. Brenneman, Esquire 44 W, Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff J,. . , " LAW OFFICES SNELBAKER. BRENNEMAN & SPARE ( . , . . CERTIFICATE OF SERVICE I;'J I, KEITH 0, BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: I"! i",; 1:;'1 ':[i :',' / FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: ,[, Carolann Wendland 1464 Boiling Springs Road Boiling Springs, P A 17007 I,"' ,f" :,' I::: ,,; L! Idh~ ::'i I' ,;'! !i] j':i I: jl i','i ':~1 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Attorney for Plaintiff MichaelJ, Malpezzi 'J ':1 ,;j ;-' ') ,I H ri ::1 ~1 Date: May 24,2001 ''."wai~M;jJ~OOiill<l'!,3l#)~"'!B.lti.'i':!i.I.~m'~;jM.~~~",~~:.J:!i:<.{,Uiir'''''':'-~i.'':';:fl;".Jtt'"IO!~!.%!...i\IDfj~ ~. - Cil t: ~h~ _\\~,~.f) J-, .;JJ.;'4J'!i'~~/h,~.~.:~.\a}1~1~~n.,.;.,;)".:-;.. ~_~.~7,_ ','.~ '..,'" ,",:"''':.'.>-''~' o'''.~ .' <<""[ '~'._.;c''"''.~ ._~ "~ ;.;.".~... ""(<~"""'-.""<'D'''k.~"".~ ",'~,[,':'" "y"" (') -v If 11'/0., ~a ~i5 d.'- ,sr.,~." ",-- (.. ..,.....,~ ~-- ~.i'-' ~('5' E; ~:}! " ~: ~ " . c..."":i -, ,-, -:r:; , ~? -., ;,.., 'I":::.:'::' :'?23 f',,) (I, -. .'~'''' :3:: :-;-;{.i..., ,{i~~ (5rJ1 c:-; " $ -.;~: :::-. 7;:) - c.., ~ .. LAW OFFICES SNEL8AKER. BRENNEMAN & SPARE '-'-...,1 '1-_ MICHAEL 1. MALPElZI, trading and doing business as MALPEZZI FUNERAL HOME, IN THE CPURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO.2001-2450 CIVIL v, CAROLANN WENDLAND, CIVIL ACTION - LAW Defendant PRAECIPE FOR JUDGMENT UPON DEF AUL T PURSUANT TO Pa,R.C,P, 1037(b) TO THE PROTHONOTARY: Please enter judgment against Defendant Carolann Wendland and in favor of Plaintiff Michael J. Malpezzi, trading and doing business as Malpezzi Funeral Home in the amount of $4,510,94, together with interest and costs of this action due to Defendant's failure to file within the required time of pleading to the Complaint in this action, A certified copy of the Complaint containing a notice to defend was served upon Defendant on May 3, 2001, I hereby certify that written notice of intention to file this Praecipe was mailed to the Defendant (the party against whom judgment is to be entered) for failure to plead to the Complaint and at least ten days prior to the date of the filing of this Praecipe, A copy of the written notice mailed to the Defendant on May 24, 2001 is attached hereto and incorporated by reference herein as "Exhibit A". SNELBAKER, BRENNEMAN & SPARE, P. C. Date: June 22,2001 (!In! 1/ft/2/l-- By: Keith 0, Brenneman, Esquire 44 W, Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff . LAW OFFICES SNELBAKER. BRENNEMAN 8: SPARE "" ~.' >' - .-, 1,,- ,-" ~ ' ~I t_, " '.., 'mh CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy ofthe foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Carolann Wendland 1464 Boiling Springs Road Boiling Springs, P A 17007 (rW;~ Keith 0, Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, p, C, 44 W, Main Street p, 0, Box 318 Mechanicsburg,PA 17055 (717) 697-8528 Attorney for Plaintiff Michael 1. Malpezzi r Date: J I44t ;r{;, ~ T ~~~~f'.l'f;'~,;;,iM1';;i!"M:$;~~~cltW.t~~j",1"'j,j_';""-"''<i4!>Y.4~~;!j,~iI1.....,;j''''''~..- <W')ilIllllililiii:illrj!~t'n='~'-'~'~"'" ,;$l{,bt_ry",. -J,',,,,J.,.w -,~ .~.,,"','-~-~~,- <"_. >t',',,,,-,- ,'~-P,--. ' .~,,~ ~ ,- V!N\I/\1\SNfBd 'l"~r >. ~ ^- l~: ~, .I:) : i~\!'.-;!""!!"J:JCi;Mn'" .,-- -"~,I ,.__----"._'1V IJ {;~ I .nl Jj;.J Ii 'U ;'-H! C' -1 ~_! t"(" _~ G f~l II 10 At]VJ.C:'......, :-!o ;.! 3:)I~:~D-G:'I!:J 0_ 0' -iJlJiiIlI .~.w. ,',',-, lire, .. II .-, ,,',-<> - ",'d - - ' L c ;;;,~-- ~. ......~:~iM.~';'l- -. MICHAEL 1. MALPEZZI, trading and doing business as MALPEZZI FUNERAL HOME, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO, 2001-2450 Civil v, " CAROLANN WENDLAND, : CIVIL ACTION - LAW Defendant TO: Carolann Wendland Date of Notice: May 24, 2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS NOTICE TO A LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, p, C. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE By: Keith 0, Brenneman, Esquire 44 W, Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff EXHIBIT A . .. .. . ~ ' ""I' LAW OFFiCES SNEL8AK~R. BRENNEMAN Be SPARE ., ,'.,1<,-,11 " ',_'d '~ -1;- ~ ~i CERTIFICATE OF SERVICE I, KEITH 0, BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Carolann Wendland 1464 Boiling Springs Road Boiling Springs, P A 17007 ~h~ Keith 0, Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street p, 0, Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Attorney for Plaintiff Michael 1. Malpezzi Date: May 24, 2001 .,... ~~!",~S;:Ji>Jl~~!!lI~~l\;,~~!&;,j!kilili~~~t.;i,!f~..,,,,,.;,',,~,j_I;,<_,-,j~tl'"'W',4W.",,J~lIJ"""-' jJlli1ill_j?'~'"-''''''~''~ ~."" =""""'""",.' ~tAS!r"'''*'- ~ -.M. ~= ~'li ..:..." , . . p. c;.;) 0 ,-, 0 C -n ,:; ;'& '- '._U ~~ m r'. -n Z '-T Z fc N :"11 U1 .,-,-' U1 C7 -" ..:~- C) r::::C) ')o'e, ;:>. T. C) "Tl -~ ('5 ~:;c...., - )o'C 0 ~~.5iTl Z --I =< 5j ,~ -< f ~ I .. ~ e $\ " l... ~ ~t '-. ~ ~ \)j '0 () '" '" rm.filLlL "j ..",,~~"; "" < ~ ,.," ~~ ,," ~ ~,,,~p'",'\C. .,'.'~"",,_," ,-","". ""." ,-', >". '~.~", .0 ~-". . ~ ." , LAW OFFICES SNELBAKER. BRENNEMAN 8: SPARE ,.,'--,,"--- ---",'.'..,'",-'.-',,"'.' MICHAEL 1. MALPEZZI, trading and doing business as MALPEZZI FUNERAL HOME, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO.2001-2450 CIVIL v, CAROLANN WENDLAND, : CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered against the Defendant in the above-captioned matter satisfied upon your docket and indices. SNELBAKER, BRENNEMAN & SPARE, p, C. Date: May 2, 2002 Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Michael J. Malpezzi II II '~/Il t Ll "1"- "'lli' '-'r.'~ r.m ~- ~. ,,~-,' ""'~ ~, - -,=~~ ~ ~..,,=""~"'. ,,;~,~~;, --~ >, " ~''''''Cd',,,,-~~~-. ..... . .c"',, ',_0._ ;>>',H. ."_ ",,' ,.' ' cr.~'__ -,;; ,- '-, ,. ,..',,~ p ~(S ~~~(:- zC---' ~("" - c'" <: -, _.-1 , ". c:, i\) ,:J?: J::J> ._< 3;! t>-,) -- - f\) rf'~